Bryan Krough v. Southwest Credit Systems, L.P.

Filing 20

PROTECTIVE ORDER by Magistrate Judge Charles F. Eick re Stipulation for Protective Order. 19 (See document for details) (vmun)

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1 GOODMAN LAW FIRM, APC 2 Brett B. Goodman (SBN 260899) 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 858.757.7262 Direct 858.757.7270 Facsimile 3 4 5 6 Attorneys for Defendant Southwest Credit Systems, L.P. 7 8 UNITED STATES DISTRICT COURT 10 GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 9 CENTRAL DISTRICT OF CALIFORNIA 11 12 BRYAN KROUGH, Plaintiff, 13 14 15 16 17 Case No.: 2:20-cv-08535-JAK-E v. STIPULATED PROTECTIVE ORDER SOUTHWEST CREDIT SYSTEMS, L.P., Defendants. 18 19 20 21 22 23 24 25 26 27 28 –1– STIPULATED PROTECTIVE ORDER 1 I. PURPOSES AND LIMITATIONS A. 3 confidential, proprietary, or private information for which special 4 protection from public disclosure and from use for any purpose other 5 than prosecuting this litigation may be warranted. Accordingly, the 6 parties hereby stipulate to and petition the Court to enter the following 7 Stipulated Protective Order. The parties acknowledge that this Order 8 does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and 10 GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 2 use extends only to the limited information or items that are entitled to 11 confidential treatment under the applicable legal principles. The parties 12 further acknowledge, as set forth in Section XIII(C), below, that this 13 Stipulated Protective Order does not entitle them to file confidential 14 information under seal; Civil Local Rule 79-5 sets forth the procedures 15 that must be followed and the standards that will be applied when a 16 party seeks permission from the Court to file material under seal. 17 II. Discovery in this action is likely to involve production of GOOD CAUSE STATEMENT 18 A. 19 financial information, including personal financial information regarding an 20 individual’s financial transactions or financial accounts, and other information 21 which is otherwise not available to the public, for which special protection from 22 public disclosure and from use for any purpose other than prosecution of this 23 action is warranted. Such confidential and proprietary materials and information 24 consist of, among other things, confidential business or financial information, 25 information regarding confidential business practices, including information 26 implicating the privacy rights of an individual, information otherwise generally 27 unavailable to the public, or which may be privileged or otherwise protected 28 from disclosure under state or federal statutes, court rules, case decisions, or This action is likely to involve the production of confidential business or –2– STIPULATED PROTECTIVE ORDER 1 common law. Accordingly, to expedite the flow of information, to 2 facilitate the prompt resolution of disputes over confidentiality of 3 discovery materials, to adequately protect information the parties are 4 entitled to keep confidential, to ensure that the parties are permitted 5 reasonable necessary uses of such material in preparation for and in the 6 conduct of trial, to address their handling at the end of the litigation, and 7 serve the ends of justice, a protective order for such information is 8 justified in this matter. It is the intent of the parties that information 9 will not be designated as confidential for tactical reasons and that GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 nothing be so designated without a good faith belief that it has been 11 maintained in a confidential, non-public manner, and there is good 12 cause why it should not be part of the public record of this case. 13 III. DEFINITIONS 14 A. Action: The above-captioned lawsuit entitled Bryan Krough v. 15 Southwest Credit Systems, L.P., Case No. 2:20-cv-08535-JAK-E. 16 B. 17 designation of information or items under this Order. 18 C. 19 of how it is generated, stored or maintained) or tangible things that 20 qualify for protection under Federal Rule of Civil Procedure 26(c), and 21 as specified above in the Good Cause Statement. 22 D. 23 as their support staff). 24 E. 25 information or items that it produces in disclosures or in responses to 26 discovery as “CONFIDENTIAL.” 27 F. 28 regardless of the medium or manner in which it is generated, stored, or Challenging Party: A Party or Non-Party that challenges the “CONFIDENTIAL” Information or Items: Information (regardless Counsel: Outside Counsel of Record and House Counsel (as well Designating Party: A Party or Non-Party that designates Disclosure or Discovery Material: All items or information, –3– STIPULATED PROTECTIVE ORDER 1 maintained (including, among other things, testimony, transcripts, and 2 tangible things), that are produced or generated in disclosures or 3 responses to discovery in this matter. 4 G. 5 matter pertinent to the litigation who has been retained by a Party or its 6 counsel to serve as an expert witness or as a consultant in this Action. 7 H. 8 Action. House Counsel does not include Outside Counsel of Record or 9 any other outside counsel. Expert: A person with specialized knowledge or experience in a House Counsel: Attorneys who are employees of a party to this GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 I. Non-Party: Any natural person, partnership, corporation, 11 association, or other legal entity not named as a Party to this action. 12 J. 13 party to this Action but are retained to represent or advise a party to this 14 Action and have appeared in this Action on behalf of that party or are 15 affiliated with a law firm which has appeared on behalf of that party, and 16 includes support staff. 17 K. 18 directors, employees, consultants, retained experts, and Outside Counsel 19 of Record (and their support staffs). 20 L. 21 or Discovery Material in this Action. 22 M. 23 support services (e.g., photocopying, videotaping, translating, preparing 24 exhibits or demonstrations, and organizing, storing, or retrieving data in 25 any form or medium) and their employees and subcontractors. 26 N. 27 designated as “CONFIDENTIAL.” 28 O. Outside Counsel of Record: Attorneys who are not employees of a Party: Any party to this Action, including all of its officers, Producing Party: A Party or Non-Party that produces Disclosure Professional Vendors: Persons or entities that provide litigation Protected Material: Any Disclosure or Discovery Material that is Receiving Party: A Party that receives Disclosure or Discovery –4– STIPULATED PROTECTIVE ORDER Material from a Producing Party. 1 2 IV. SCOPE 3 A. The protections conferred by this Stipulation and Order cover not 4 only Protected Material (as defined above), but also (1) any information 5 copied or extracted from Protected Material; (2) all copies, excerpts, 6 summaries, or compilations of Protected Material; and (3) any 7 testimony, conversations, or presentations by Parties or their Counsel 8 that might reveal Protected Material. 9 B. Any use of Protected Material at trial shall be governed by the GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 orders of the trial judge. This Order does not govern the use of Protected 11 Material at trial. 12 V. DURATION 13 Even after final disposition of this litigation, the confidentiality 14 obligations imposed by this Order shall remain in effect until a 15 Designating Party agrees otherwise in writing or a court order otherwise 16 directs. Final disposition shall be deemed to be the later of (1) dismissal 17 of all claims and defenses in this Action, with or without prejudice; and 18 (2) final judgment herein after the completion and exhaustion of all 19 appeals, rehearings, remands, trials, or reviews of this Action, including 20 the time limits for filing any motions or applications for extension of 21 time pursuant to applicable law. 22 23 24 VI. DESIGNATING PROTECTED MATERIAL A. Exercise of Restraint and Care in Designating Material for Protection 25 1. Each Party or Non-Party that designates information or 26 items for protection under this Order must take care to limit any 27 such designation to specific material that qualifies under the 28 appropriate standards. The Designating Party must designate for –5– STIPULATED PROTECTIVE ORDER 1 protection only those parts of material, documents, items, or oral 2 or written communications that qualify so that other portions of 3 the material, documents, items, or communications for which 4 protection is not warranted are not swept unjustifiably within the 5 ambit of this Order. 6 2. 7 prohibited. Designations that are shown to be clearly unjustified or 8 that have been made for an improper purpose (e.g., to 9 unnecessarily encumber the case development process or to Mass, indiscriminate, or routinized designations are GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 impose unnecessary expenses and burdens on other parties) may 11 expose the Designating Party to sanctions. 12 3. 13 information or items that it designated for protection do not 14 qualify for protection, that Designating Party must promptly notify 15 all other Parties that it is withdrawing the inapplicable 16 designation. 17 B. If it comes to a Designating Party’s attention that Manner and Timing of Designations 18 1. Except as otherwise provided in this Order (see, e.g., Section 19 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure 20 or Discovery Material that qualifies for protection under this Order 21 must be clearly so designated before the material is disclosed or 22 produced. 23 2. 24 following: Designation in conformity with this Order requires the 25 a. For information in documentary form (e.g., paper or 26 electronic documents, but excluding transcripts of 27 depositions or other pretrial or trial proceedings), that the 28 Producing Party affix at a minimum, the legend –6– STIPULATED PROTECTIVE ORDER 1 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), 2 to each page that contains protected material. If only a 3 portion or portions of the material on a page qualifies for 4 protection, the Producing Party also must clearly identify the 5 protected portion(s) (e.g., by making appropriate markings 6 in the margins). 7 b. 8 available for inspection need not designate them for 9 protection until after the inspecting Party has indicated A Party or Non-Party that makes original documents GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 which documents it would like copied and produced. During 11 the inspection and before the designation, all of the material 12 made available for inspection shall be deemed 13 “CONFIDENTIAL.” After the inspecting Party has identified 14 the documents it wants copied and produced, the Producing 15 Party must determine which documents, or portions thereof, 16 qualify for protection under this Order. Then, before 17 producing the specified documents, the Producing Party 18 must affix the “CONFIDENTIAL legend” to each page that 19 contains Protected Material. If only a portion or portions of 20 the material on a page qualifies for protection, the Producing 21 Party also must clearly identify the protected portion(s) (e.g., 22 by making appropriate markings in the margins). 23 c. 24 Designating Party identify the Disclosure or Discovery 25 Material on the record, before the close of the deposition all 26 protected testimony. 27 d. 28 document and for any other tangible items, that the For testimony given in depositions, that the For information produced in form other than –7– STIPULATED PROTECTIVE ORDER 1 Producing Party affix in a prominent place on the exterior of 2 the container or containers in which the information is 3 stored the legend “CONFIDENTIAL.” If only a portion or 4 portions of the information warrants protection, the 5 Producing Party, to the extent practicable, shall identify the 6 protected portion(s). 7 C. Inadvertent Failure to Designate 1. 9 qualified information or items does not, standing alone, waive the 10 GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 8 Designating Party’s right to secure protection under this Order for 11 such material. Upon timely correction of a designation, the 12 Receiving Party must make reasonable efforts to assure that the 13 material is treated in accordance with the provisions of this Order. 14 15 If timely corrected, an inadvertent failure to designate VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS A. Timing of Challenges 16 1. 17 confidentiality at any time that is consistent with the Court’s 18 Scheduling Order. 19 B. Any party or Non-Party may challenge a designation of Meet and Confer 20 1. The Challenging Party shall initiate the dispute resolution 21 process under Local Rule 37.1 et seq. 22 C. The burden of persuasion in any such challenge proceeding shall 23 be on the Designating Party. Frivolous challenges, and those made for 24 an improper purpose (e.g., to harass or impose unnecessary expenses 25 and burdens on other parties) may expose the Challenging Party to 26 sanctions. Unless the Designating Party has waived or withdrawn the 27 confidentiality designation, all parties shall continue to afford the 28 material in question the level of protection to which it is entitled under –8– STIPULATED PROTECTIVE ORDER 1 2 3 the Producing Party’s designation until the Court rules on the challenge. VIII. ACCESS TO AND USE OF PROTECTED MATERIAL A. Basic Principles 4 1. A Receiving Party may use Protected Material that is 5 disclosed or produced by another Party or by a Non-Party in 6 connection with this Action only for prosecuting, defending, or 7 attempting to settle this Action. Such Protected Material may be 8 disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 terminated, a Receiving Party must comply with the provisions of 11 Section XIV below. 12 2. 13 Receiving Party at a location and in a secure manner that ensures 14 that access is limited to the persons authorized under this Order. 15 B. Protected Material must be stored and maintained by a Disclosure of “CONFIDENTIAL” Information or Items 16 1. Unless otherwise ordered by the Court or permitted in 17 writing by the Designating Party, a Receiving Party may disclose 18 any information or item designated “CONFIDENTIAL” only to: 19 a. The Receiving Party’s Outside Counsel of Record in 20 this Action, as well as employees of said Outside Counsel of 21 Record to whom it is reasonably necessary to disclose the 22 information for this Action; 23 b. 24 House Counsel) of the Receiving Party to whom disclosure is 25 reasonably necessary for this Action; 26 c. 27 Party to whom disclosure is reasonably necessary for this 28 Action and who have signed the “Acknowledgment and The officers, directors, and employees (including Experts (as defined in this Order) of the Receiving –9– STIPULATED PROTECTIVE ORDER 1 Agreement to Be Bound” (Exhibit A); 2 d. The Court and its personnel; 3 e. Court reporters and their staff; 4 f. Professional jury or trial consultants, mock jurors, and 5 Professional Vendors to whom disclosure is reasonably 6 necessary or this Action and who have signed the 7 “Acknowledgment and Agreement to be Bound” attached as 8 Exhibit A hereto; 9 g. The author or recipient of a document containing the GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 information or a custodian or other person who otherwise 11 possessed or knew the information; 12 h. 13 witnesses, in the Action to whom disclosure is reasonably 14 necessary provided: (i) the deposing party requests that the 15 witness sign the “Acknowledgment and Agreement to Be 16 Bound;” and (ii) they will not be permitted to keep any 17 confidential information unless they sign the 18 “Acknowledgment and Agreement to Be Bound,” unless 19 otherwise agreed by the Designating Party or ordered by the 20 Court. Pages of transcribed deposition testimony or exhibits 21 to depositions that reveal Protected Material may be 22 separately bound by the court reporter and may not be 23 disclosed to anyone except as permitted under this 24 Stipulated Protective Order; and 25 i. 26 supporting personnel, mutually agreed upon by any of the 27 parties engaged in settlement discussions. During their depositions, witnesses, and attorneys for Any mediator or settlement officer, and their 28 – 10 – STIPULATED PROTECTIVE ORDER 1 IX. PROTECTED MATERIAL SUPOENAED OR ORDERED 2 PRODUCED 3 A. 4 litigation that compels disclosure of any information or items designated 5 in this Action as “CONFIDENTIAL,” that Party must: IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other 6 1. Promptly notify in writing the Designating Party. Such 7 notification shall include a copy of the subpoena or court order; 8 2. 9 subpoena or order to issue in the other litigation that some or all of Promptly notify in writing the party who caused the GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 the material covered by the subpoena or order is subject to this 11 Protective Order. Such notification shall include a copy of this 12 Stipulated Protective Order; and 13 3. 14 to be pursued by the Designating Party whose Protected Material 15 may be affected. Cooperate with respect to all reasonable procedures sought 16 B. 17 served with the subpoena or court order shall not produce any 18 information designated in this action as “CONFIDENTIAL” before a 19 determination by the Court from which the subpoena or order issued, 20 unless the Party has obtained the Designating Party’s permission. The 21 Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material and nothing in these 23 provisions should be construed as authorizing or encouraging a 24 Receiving Party in this Action to disobey a lawful directive from another 25 court. 26 X. If the Designating Party timely seeks a protective order, the Party A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 28 A. The terms of this Order are applicable to information produced by – 11 – STIPULATED PROTECTIVE ORDER 1 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 2 information produced by Non-Parties in connection with this litigation 3 is protected by the remedies and relief provided by this Order. Nothing 4 in these provisions should be construed as prohibiting a Non-Party from 5 seeking additional protections. 6 B. 7 to produce a Non-Party’s confidential information in its possession, and 8 the Party is subject to an agreement with the Non-Party not to produce 9 the Non-Party’s confidential information, then the Party shall: In the event that a Party is required, by a valid discovery request, Promptly notify in writing the Requesting Party and the GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 1. 11 Non-Party that some or all of the information requested is subject 12 to a confidentiality agreement with a Non-Party; 13 2. 14 Stipulated Protective Order in this Action, the relevant discovery 15 request(s), and a reasonably specific description of the information 16 requested; and 17 3. 18 the Non-Party, if requested. Promptly provide the Non-Party with a copy of the Make the information requested available for inspection by If the Non-Party fails to seek a protective order from this court 19 C. 20 within 14 days of receiving the notice and accompanying information, 21 the Receiving Party may produce the Non-Party’s confidential 22 information responsive to the discovery request. If the Non-Party timely 23 seeks a protective order, the Receiving Party shall not produce any 24 information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by 26 the court. Absent a court order to the contrary, the Non-Party shall bear 27 the burden and expense of seeking protection in this court of its 28 Protected Material. – 12 – STIPULATED PROTECTIVE ORDER 1 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 A. If a Receiving Party learns that, by inadvertence or otherwise, it 3 has disclosed Protected Material to any person or in any circumstance 4 not authorized under this Stipulated Protective Order, the Receiving 5 Party must immediately (1) notify in writing the Designating Party of the 6 unauthorized disclosures, (2) use its best efforts to retrieve all 7 unauthorized copies of the Protected Material, (3) inform the person or 8 persons to whom unauthorized disclosures were made of all the terms of 9 this Order, and (4) request such person or persons to execute the GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 “Acknowledgment and Agreement to be Bound” that is attached hereto 11 as Exhibit A. 12 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR 13 OTHERWISE PROTECTED MATERIAL 14 A. 15 certain inadvertently produced material is subject to a claim of privilege 16 or other protection, the obligations of the Receiving Parties are those set 17 forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is 18 not intended to modify whatever procedure may be established in an e- 19 discovery order that provides for production without prior privilege 20 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 21 the parties reach an agreement on the effect of disclosure of a 22 communication or information covered by the attorney-client privilege 23 or work product protection, the parties may incorporate their agreement 24 in the Stipulated Protective Order submitted to the Court. 25 26 When a Producing Party gives notice to Receiving Parties that XIII. MISCELLANEOUS A. Right to Further Relief 27 1. 28 seek its Nothing in this Order abridges the right of any person to modification by the Court in the future. – 13 – STIPULATED PROTECTIVE ORDER 1 B. Right to Assert Other Objections By stipulating to the entry of this Protective Order, no Party 2 1. 3 waives any right it otherwise would have to object to disclosing or 4 producing any information or item on any ground not addressed in 5 this Stipulated Protective Order. Similarly, no Party waives any 6 right to object on any ground to use in evidence of any of the 7 material covered by this Protective Order. 8 C. Filing Protected Material 1. 9 A Party that seeks to file under seal any Protected Material GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 must comply with Civil Local Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the 12 sealing of the specific Protected Material at issue. If a Party's 13 request to file Protected Material under seal is denied by the Court, 14 then the Receiving Party may file the information in the public 15 record unless otherwise instructed by the Court. 16 XIV. FINAL DISPOSITION After the final disposition of this Action, as defined in Section V, 17 A. 18 within sixty (60) days of a written request by the Designating Party, each 19 Receiving Party must return all Protected Material to the Producing 20 Party or destroy such material. As used in this subdivision, “all 21 Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the 23 Protected Material. Whether the Protected Material is returned or 24 destroyed, the Receiving Party must submit a written certification to the 25 Producing Party (and, if not the same person or entity, to the 26 Designating Party) by the 60 day deadline that (1) identifies (by 27 category, where appropriate) all the Protected Material that was 28 returned or destroyed and (2) affirms that the Receiving Party has not – 14 – STIPULATED PROTECTIVE ORDER 1 retained any copies, abstracts, compilations, summaries or any other 2 format reproducing or capturing any of the Protected Material. 3 Notwithstanding this provision, Counsel are entitled to retain an 4 archival copy of all pleadings, motion papers, trial, deposition, and 5 hearing transcripts, legal memoranda, correspondence, deposition and 6 trial exhibits, expert reports, attorney work product, and consultant and 7 expert work product, even if such materials contain Protected Material. 8 Any such archival copies that contain or constitute Protected Material 9 remain subject to this Protective Order as set forth in Section V. GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 B. Any violation of this Order may be punished by any and all 11 appropriate measures including, without limitation, contempt 12 proceedings and/or monetary sanctions. 13 14 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 15 16 Dated: April 27, 2021 /s/ Alejandro E. Figueroa Alejandro E. Figueroa Attorney for Plaintiff Dated: April 27, 2021 /s/ Brett B. Goodman Brett B. Goodman Attorney for Defendant 17 18 19 20 21 22 23 24 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 25 26 27 Dated: 4/28/2021 /s/ CHARLES F. EICK HONORABLE CHARLES F. EICK United States Magistrate Judge 28 – 15 – STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, 4 [print or type full name], of [print or type full address], declare under penalty of perjury that I 5 6 have read in its entirety and understand the Stipulated Protective Order that 7 was issue by the United States District Court for the Central District of 8 California on __________ [DATE] in the case of Bryan Krough v. Southwest 9 Credit Systems, L.P., Case No. 2:20-cv-08535-JAK-E. I agree to comply with and GOODMAN LAW FIRM, APC 11440 W. Bernardo Ct., Suite 300 San Diego, CA 92127 10 to be bound by all the terms of this Stipulated Protective Order and I 11 understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that 13 I will not disclose in any manner any information or item that is subject to this 14 Stipulated Protective Order to any person or entity except in strict compliance 15 with the provisions of this Order. I further agree to submit to the jurisdiction of the United States District 16 17 Court for the Central District of California for the purpose of enforcing the 18 terms of this Stipulated Protective Order, even if such enforcement 19 proceedings occur after termination of this action. I hereby appoint [print or type full name] of 20 [print 21 or type full address and telephone number] as my California agent for service 22 of process in connection with this action or any proceedings related to 23 enforcement of this Stipulated Protective Order. 24 Date: 25 City and State where sworn and signed: 26 Printed Name: 27 Signature: 28 – 16 – STIPULATED PROTECTIVE ORDER 1 SIGNATURE CERTIFICATION PURSUANT TO L.R. 5-4.3.4(2)(i) 2 I have obtained authorization from the above signatories to file the above- 3 referenced document, and the above signatories concur in the filing’s content. 4 5 GOODMAN LAW FIRM, APC 6 By: /s/ Brett B. Goodman Brett B. Goodman Attorneys for Defendant 7 8 9 10 GOODMAN LAW FIRM, APC 11440 w. Bernardo Ct., Suite 300 San Diego, CA. 92127 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SIGNATURE CERTIFICATION 1 CERTIFICATE OF SERVICE 2 I certify that on April 28, 2021, a copy of the foregoing was filed and served 3 electronically in the ECF system. Notice of this filing will be sent to the parties of 4 record by operation of the Court’s electronic filing system. Parties may access this 5 filing through the Court’s system. 6 7 8 9 10 GOODMAN LAW FIRM, APC 11440 w. Bernardo Ct., Suite 300 San Diego, CA. 92127 11 DATED: April 28, 2021 GOODMAN LAW FIRM, APC By: /s/ Brett B. Goodman Brett B. Goodman 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CERTIFICATE OF SERVICE

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